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									                United States General Accounting Office

GAO             Report to the Honorable
                James M. Inhofe, U.S. Senate



February 2000

                STRUCTURED
                SETTLEMENTS
                The Department of
                Justice’s Selection
                and Use of Annuity
                Brokers




GAO/GGD-00-45
United States General Accounting Office                                                           General Government Division
Washington, D.C. 20548




                                    B-283058
                                    February 16, 2000
                                    The Honorable James M. Inhofe
                                    United States Senate

                                    Dear Senator Inhofe:

                                    The federal government solicits the services of private brokers to assist in
                                    structuring settlements with claimants in lawsuits against federal agencies.
                                    Because private brokers can earn lucrative commissions from insurance
                                    companies, it is important that the Department of Justice (DOJ) has
                                    criteria and a system of controls to promote fairness and avoid the
                                    appearance of favoritism in selecting these brokers. This report responds
                                    to your request that we review DOJ’s policy and guidance for selecting
                                    structured settlement brokers. As agreed with your office, this report (1)
                                    discusses the policies and guidance for selecting structured settlement
                                                                                    1
                                    brokers used by DOJ and six selected agencies and (2) provides a list of
                                    the structured settlement brokerage companies used by DOJ and the
                                    number of settlements awarded to each company since May 1997.

                                    In 1993 and 1997, DOJ issued policies and guidance on the selection of
Results in Brief                    structured settlement brokers to promote fairness and to avoid the
                                    appearance of favoritism. DOJ officials told us that its policies and
                                    guidelines permit some discretion and that when selecting a particular
                                    broker, they generally relied on such factors as reputation, past
                                    experience, knowledge, and location. However, DOJ officials also told us
                                    they were unable to specify reasons why attorneys selected particular
                                    brokers to settle specific cases, because DOJ did not require
                                                                                                     2
                                    documentation of these decisions. Without an internal control requiring
                                    that the reasons for selecting a particular settlement broker be
                                    documented and readily available for examination, it is more difficult to
                                    verify that selection policies and guidelines were followed and, in turn, to
                                    avoid the appearance of favoritism and preferential treatment.

                                    Overall, the six federal agencies we surveyed described policies and
                                    guidance in selecting structured settlement brokers that were similar to

                                    1
                                    The six selected agencies were the Departments of Health and Human Services (HHS) and Veterans
                                    Affairs (VA); the Air Force, Army, and Navy; and the United States Postal Service.
                                    2
                                     The Comptroller General’s Standards for Internal Control in the Federal Government (GAO/AIMD-00-
                                    21.3.1) requires that all transactions and significant events are to be clearly documented and that the
                                    documentation is to be readily available for examination.




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             DOJ’s. Also, like DOJ, none of the agencies had internal controls requiring
             their attorneys to document their reasons for selecting a specific broker.
             One agency had a written supplemental policy governing the use of
             structured settlements, but it did not require documentation of decisions.
             Officials at the other five federal agencies said they also generally relied on
             such factors as reputation, past experience, knowledge, and location for
             selecting a particular structured settlement broker. However, as was the
             case with DOJ, the reasons why particular brokers were selected for
             specific cases were not documented.

             Our review of the list of structured settlement brokerage companies used
             by DOJ and the number of settlements assigned to each company showed
             that DOJ selected a few companies to handle most of its structured
                                  3
             settlement business. According to DOJ, the companies frequently have
             multiple offices and brokers that compete with each other within the same
             company. Thus, a simple count of the number of companies could be
             misleading. Although DOJ used 27 different structured settlement
             companies to settle 242 claims for about $236 million between May 1, 1997,
             and May 1, 1999, 70 percent (169 cases) were awarded to 4 brokerage
             companies. Of the remaining 23 companies, none were awarded more than
             17 cases each.

             We are recommending that DOJ (1) establish internal controls that require
             its officials to document the reasons for selecting a particular broker or
             brokerage company to settle a case and (2) disseminate this guidance to
             federal agencies responsible for handling structured settlement claims.

             A structured settlement is the payment of money for a personal injury
Background   claim in which at least part of the settlement calls for future payment. The
             payments may be scheduled for any length of time, even as long as the
             claimant’s lifetime, and may consist of installment payments and/or future
             lump sums. Payments can be in fixed amounts, or they can vary. The
             schedule is structured to meet the financial needs of the claimant.
                                                                                                                       4
             For years, structured settlements have been widely used in the tort area to
             compensate severely injured, often profoundly disabled, tort victims.
             Cases generally involve medical malpractice and other personal injury. The
                                             5
             Federal Tort Claims Act (FTCA) is the statute by which the United States
             3
                 Thirteen of the 94 U.S. Attorneys offices did not provide structured settlement data.
             4
             A tort is a civil wrong, not including a breach of contract, for which the injured party is entitled to
             damages.
             5
                 28 U.S.C. §§1346(b), 2671-2680.




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                                                                                                        6
authorizes tort suits to be brought against itself. With certain exceptions,
it makes the United States liable for injuries caused by the negligent or
wrongful act or omission of any federal employee acting within the scope
of his or her employment, in accordance with the law of the state where
the act or omission occurred. Generally, a tort claim against the United
States is barred unless it is presented in writing to the appropriate federal
agency within 2 years after the claim accrues.

In addition, the National Childhood Vaccine Injury Act of 1986, as
amended, created a mechanism for compensating persons injured by
certain pharmaceutical products. The act established the National Vaccine
                                        7
Injury Compensation Program (VICP) as an alternative to traditional
product liability and/or medical malpractice litigation for persons injured
by their receipt of one or more of the standard childhood vaccines
                                                              8
required for admission to schools and by certain employers. VICP is “no-
fault.” That is, claimants need not establish that the vaccine was defective,
or that any degree of negligence was involved in its administration. The
only liability-related question is causation—did the vaccine cause the
injury for which compensation is sought?

The industry standard of practice requires the use of a licensed broker or
                                                                      9
insurance agent to obtain a settlement annuity. DOJ’s Civil Division
estimated that structured settlements constitute between 1 and 2 percent
of all settlements in litigated tort cases. Brokers receive no direct
compensation from the government; rather, they are compensated by the
insurance company from whom the annuity is purchased. The insurance
company typically pays the brokers’ commissions, which amount to 3 or 4
percent of the annuity premium. The government attorney negotiating the
case is responsible for selecting the broker.

6
 Three major exceptions under which the United States may not be held liable, even in circumstances
where a private person could be held liable under state law, are the Feres doctrine, which prohibits
suits by military personnel for injuries sustained incident to service; the discretionary function
exception, which immunizes the United States for acts or omissions of its employees that involve
policy judgments; and the intentional tort exception, which precludes suits against the United States
for assault and battery, and certain other intentional torts, unless they are committed by federal law
enforcement or investigative officials.
7
    42 U.S.C. §§ 300aa-10 et seq.
8
 Currently, the vaccines covered under the Program are those administered to protect against
diphtheria, tetanus, pertussis (whooping cough), measles, mumps, rubella (German measles), polio,
hepatitis B, varicella (chicken pox), Haemophilus influenzae type b, and rotavirus.
9
 The responsibilities of DOJ’s Civil Division include representing the United States, its agencies, and its
employees in suits where monetary judgments are sought for damages resulting from negligent or
wrongful acts.




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                         Structured settlements for the federal government are negotiated by the
                         Civil Division’s torts attorneys, Assistant United States Attorneys (AUSAs),
                         or agency attorneys. AUSAs are authorized to settle certain cases. An
                         agency may not settle a tort claim for more than $25,000 without the prior
                         written approval of the Attorney General or her designee, unless the
                         Attorney General has delegated to the head of the agency the authority to
                               10
                         do so.

                         To ascertain DOJ’s policies and guidance for the selection of settlement
Objectives, Scope, and   brokers, we reviewed the Torts Branch handbook, Damages Under the
Methodology              Federal Tort Claim Act (section V: Settlements), and other relevant
                         documents pertaining to broker selection policies. In addition, to obtain
                         information about the procedures used to select brokers, we interviewed
                         attorneys in DOJ’s Civil Division and representatives from the Executive
                         Office for United States Attorneys (EOUSA).

                         To obtain information on broker selection policies and guidance used by
                         federal agencies, we asked DOJ to identify other federal agencies that
                         handled structured settlement claims. DOJ identified six agencies—HHS
                         and VA; the Air Force, Army, and Navy; and the U.S. Postal Service. At
                         each of the six agencies, we met with officials who were responsible for
                         negotiating structured settlement claims. We discussed their policies and
                         procedures for selecting structured settlement brokers and asked them
                         what factors they considered during the selection process. In addition, we
                         obtained and reviewed a copy of the Army’s standard operating
                         procedures pertaining to structured settlements. Also, we asked the six
                         agencies to supply information pertaining to the number of structured
                         settlements since May 1997.

                         To provide the list of DOJ’s structured settlement annuities between May
                         1, 1997, and May 1, 1999, we used data DOJ collected from the Civil
                         Division and the United States Attorneys Offices. The Civil Division’s data
                         came from the Torts Branch, which routinely handles structured
                         settlements. The United States Attorneys’ data were collected by EOUSA
                         and include all the data received by EOUSA as of August 12, 1999. As of
                         that date, 34 of the 94 United States Attorneys offices had reported annuity
                                                                      11
                         settlements during the relevant time period. We did not verify the
                         accuracy of the information collected from the Torts Branch or EOUSA.


                         10
                            For example, the Attorney General has delegated the authority to settle tort claims of up to $200,000
                         to the Secretary of Defense.
                         11
                              Thirteen offices did not respond to EOUSA’s request for information.




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                        To gain a broader understanding of structured settlements, we met with
                        the Executive Vice President of the National Structured Settlement Trade
                                             12
                        Association (NSSTA). We obtained information concerning brokers
                        working with federal structured settlements.

                        We did our audit work between June and December 1999 in accordance
                        with generally accepted government auditing standards. We requested
                        comments on a draft of this report from the United States Attorney
                        General or her designee. Also, in January we discussed the contents of
                        this report with VA’s Assistant General Counsel; U.S. Postal Service’
                        Claims Division Counsel; and the Army’s Torts Claims Division Chief.
                        Also, we obtain comments for the Air Force and Navy from DoD’s Senior
                        Report Analysis for the GAO Affairs Directorate. In addition, we spoke
                        with HHS’ Associate General Counsel. The written and oral comments we
                        received are discussed near the end of the report.

                        Although DOJ had established policies and guidance for the selection of
Federal Policies for    structured settlement brokers, the policies and guidance did not include an
Selecting Structured    internal control requiring attorneys to document their reasons for selecting
Settlement Brokers      a specific broker. Similarly, although the six agencies we reviewed said
                        they generally followed DOJ’s policy guidance for selecting a structured
Lacked Adequate         settlement broker, they were not required to document their reasons for
Internal Control        selecting a particular broker. None of these agencies documented the
                        reasons why they selected particular brokers.

DOJ Did Not Document    DOJ had established policies and guidance governing the selection of
                        structured settlement brokers, but it did not require that the reasons for
Reasons for Selecting   selecting a specific broker be documented. On July 16, 1993, the Director
Brokers                 of the Civil Division’s Torts Branch, which is responsible for FTCA claims
                        and litigation, issued a memorandum that was intended to supplement the
                        guidance on structured settlements in the Damages Handbook and to
                        codify previous informal guidance on the selection of structured
                        settlement brokers. Neither the Damages Handbook nor the memorandum
                        addressed documenting the reasons for selecting a specific broker.

                        On June 30, 1997, the Acting Associate Attorney General expanded the
                        policy guidance by issuing a memorandum to United States Attorneys.
                        However, the new guidance did not address documenting the reasons for


                        12
                           NSSTA is an organization composed of more than 500 members who negotiate and fund structured
                        settlements of tort and worker’s compensation claims involving persons with serious, long-term
                        physical injuries. Founded in 1986, NSSTA’s stated mission is to advance the use of structured
                        settlements as a means of resolving physical injury claims.




                        Page 5                                  GAO/GGD-00-45 Selection and Use of Annuity Brokers
  B-283058




  broker selections. Generally, the 1997 policy guidance outlined procedures
  concerning the selection of structured settlement brokers. These included:

• Every broker was to be given an opportunity to promote its services.

• No lists of “approved,” “preferred,” or “disapproved” brokers were to be
  maintained.

• Brokers who performed well in the past were to be appropriately
  considered for repeated use: however, such use could not be to the
  exclusion of new brokers.

• Attorneys were expected to look to supervisory attorneys for assistance;
  however, final broker selection was the responsibility of the attorney
  negotiating the settlement.

• When a structured settlement in an FTCA case included a reversionary
          13
  interest in favor of the United States, the Torts Branch’s FTCA staff was
  to be consulted to maintain appropriate records and ensure consistency.

• Any activity tending toward an appearance of favoritism, any action
  contrary to any of the above rules, or any activity incongruent with the
  spirit of the memorandum was to be scrupulously avoided.

  According to agency officials, attorneys sometimes asked each other about
  their experiences with a particular broker, but the attorney negotiating the
  case is responsible for making the final broker selection, and is not
  required to consult with the FTCA staff. DOJ officials told us that in the
  absence of a requirement to do so, they did not document the reasons for
  selecting particular settlement brokers.

  The Comptroller General’s guidance on internal controls in the federal
  government, Standards for Internal Control in the Federal Government
  (GAO/AIMD-00-21.3.1), requires that all transactions and significant events
  are to be clearly documented and that the documentation is to be readily
  available for examination. The documentation should appear in
  management directives, administrative policies, or operating manuals and
  may be in paper or electronic form. All documentation and records should
  be properly managed and maintained.



  13
       Reversionary interest is the interest that a person has in the reversion of lands or other property.




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                                                                                           14
Selected Agencies Did Not     During 1999, DOJ provided its policy guidance to the six selected
                              agencies in our review—HHS and VA; the Air Force, Army, and Navy; and
Document Reasons for          the Postal Service. Generally, the selection processes the agencies said
Selecting Brokers             they had were similar to DOJ’s, (e.g., the attorney negotiating a case made
                              the final decision, no list of approved or disapproved structured settlement
                              brokers was maintained).

                              Five agencies in our review identified various factors they considered
                              when selecting a structured settlement broker. For example:

                            • HHS, Postal Service, and VA officials told us that they tended to select
                              brokers with offices in the Washington, D.C., area. According to VA
                              officials, the use of distantly located brokers created problems because of
                              (1) differences in time zones and (2) the inability of nonlocal brokers to
                              physically conduct work on short notice.

                            • Air Force, Navy, and VA officials told us that they put considerable weight
                              on an impressive presentation given by the broker’s firm.

                            • HHS, Navy, Postal Service, and VA officials said they looked at the broker’s
                              knowledge and experience in handling structured settlement cases for the
                              federal government and based their selections on positive past
                              experiences.

                            • Navy and Postal Service officials said they looked for brokers with a
                              reputation for being dependable and responsible.

                              In addition, the Army had established supplemental policies governing the
                              selection of structured settlement brokers. According to the Army’s
                              standard operating procedures, brokers were to be selected on a case-by-
                              case basis according to the following criteria: (1) the broker’s ability to
                              become a member of the negotiating team, participate in negotiations, and
                              travel at his or her own expense; (2) the selecting administrative officer’s
                              previous interviews with or knowledge of the broker; (3) the broker’s
                              ability to present his views verbally (if the case requires in-person
                              negotiations); and (4) the broker’s experience if the administrative officer
                              is inexperienced. In certain more specialized cases, the selecting
                              administrative officer’s choice of a specific broker must be approved by a
                              higher authority.


                              14
                               This guidance was contained in a June 30, 1997, memorandum from the Acting Associate Attorney
                              General to the United States Attorneys regarding the selection of structured settlement brokers.




                              Page 7                                   GAO/GGD-00-45 Selection and Use of Annuity Brokers
                                       B-283058




                                       Even though federal agencies we surveyed said they provided policy
                                       guidance on broker selection, none of them required documentation of the
                                       reasons for selecting a structured settlement broker. In the absence of this
                                       requirement, none documented the reason for selection.

                                       DOJ has selected several structured settlement brokerage companies to
DOJ Selected a Few                     handle most of the structured settlement claims. Between May 1, 1997,
Brokers to Handle                      and May 1, 1999, DOJ used 27 different structured settlement brokerage
Most Settlements                       companies to settle 242 claims for $236 million. (See table 1 for the
                                       number and total annuity costs of annuity settlements handled by
Claims                                 brokers.) Of the 242 claims awarded, 70 percent (169 cases) were awarded
                                       to 4 brokerage companies. One of the four companies was awarded 30
                                       percent (72 cases) of the total number of cases. The remaining 23
                                       companies were awarded 30 percent of the total number of cases.




Table 1: Annuity Settlements for DOJ              a
(May1997 to May 1999)                  Brokerage                        Number of settlements          Total annuity cost
                                       AIG Life Insurance Company                           1                    $97,000
                                       Allstate Life Insurance Company                      1                     99,333
                                       Brant Hickey & Associates                           10                  4,894,998
                                       Canada Life Assurance
                                       Company                                              1                    100,000
                                       Creative Settlement Consultants                      8                  8,249,758
                                       Delta Group                                         26                 33,800,720
                                       Garrett Wong & Associates                            1                  1,000,000
                                       GE Capital Assurance                                 1                    150,000
                                       Halpern Group                                        1                    484,505
                                       Huver & Associates, Inc.                             7                  3,550,800
                                       JMW Settlements, Inc.                               35                 29,235,685
                                       Joe Huver, Amicus Group                              3                    760,000
                                       Kenneth H. Wells & Associates                        1                     16,430
                                       Legal Economic Evaluations, Inc.                     1                    156,500
                                       Minet Settlement Services, Inc.                      1                    171,719
                                       Near North Financial Group                           2                    406,946
                                       Near North Insurance Brokerage,
                                       Inc.                                                 2                    700,129
                                       Pension Company                                      2                  1,351,381
                                       Ringler Associates, Inc.                            36                 24,039,764
                                       Settlement Associates, Inc.                         17                 21,691,697
                                       Settlement Planning Associates                       5                  3,339,803
                                       Settlement Professionals, Inc.                       1                    500,000
                                       Sheerin Corporation                                  2                    689,810
                                       Structured Financial Associates                     72                 99,283,574




                                       Page 8                            GAO/GGD-00-45 Selection and Use of Annuity Brokers
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                    Structured Funding Group                                         2                        600,000
                    Structured Settlement Company                                    2                        380,000
                    Summit Settlement Services                                       1                        250,000
                    Total                                                          242                   $236,000,552
                    Note 1: DOJ settlements may Include annuity settlements for the Torts Branch, Civil Division and the
                    U.S. Attorney Offices.
                    Note 2: Thirteen U.S. Attorney offices did not provide structured settlement data.
                    a
                      Includes four insurance carriers (AIG Life Insurance Company, Allstate Life Insurance Company, GE
                    Capital Assurance, and Canada Life Assurance Company) because the name of the structured
                    settlement broker was not included in the data.
                    Source: DOJ data.
                    Because DOJ did not document the reasons for selecting a particular
                    broker, DOJ officials could not specifically say why certain companies
                    received more business than others. However, as noted previously, DOJ
                    officials cited a variety of reasons for selecting a specific structured
                    settlement broker, such as experience, dependability, and knowledge of
                    federal structured claims.

                    According to DOJ, the companies frequently have multiple offices and
                    brokers that compete with each other within the same company. Thus, a
                    simple count of the number of companies could be misleading.

                    DOJ has developed policies and guidance for selecting structured
Conclusions         settlement brokers and disseminated this information to the six other
                    federal agencies with authority to handle structured settlement claims that
                    we contacted. However, the policies and guidance lacked an internal
                    control requiring that the reasons for selecting a broker be documented
                    and readily available for examination. This is important because without
                    documentation of transactions or other significant events, DOJ can not be
                    certain that its policies and guidance on selecting structured settlement
                    brokers are being followed. Further, without documentation on the
                    reasons settlement brokers were selected, it is more difficult to avoid the
                    appearance of favoritism and preferential treatment in a situation where
                    some brokers get significantly more business than others.

                    We recommend that the Attorney General of the United States direct the
Recommendations     Director of the Torts Branch responsible for FTCA claims and litigation,
                    Civil Division, to

                  • develop an adequate internal control to ensure that the reasons for
                    selecting structured settlement brokers are always fully documented and
                    readily available for examination; and
                  • disseminate this guidance to federal agencies, including those in our
                    survey, responsible for handling structured settlement claims.



                    Page 9                                    GAO/GGD-00-45 Selection and Use of Annuity Brokers
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                  We requested comments on a draft of this report from the Attorney
Agency Comments   General or her designee. On January 18, 2000, the Acting Assistant
                  Attorney General, Civil Division provided us with written comments,
                  which are printed in full in appendix I. The Justice Department expressed
                  appreciation that the report “outlines the many steps undertaken by the
                  Department to ensure fairness in the broker selection process.”

                  DOJ said its existing policies and guidance to ensure that the selection of
                  brokers is fair are effective. Therefore, it disagreed with our
                  recommendation that DOJ implement an adequate internal control to
                  ensure that the reasons for selecting a specific structured settlement
                  broker are always fully documented and readily available for examination.
                  DOJ noted that the Comptroller General’s Standards for Internal Control in
                  the Federal Government specify that management should design and
                  implement internal controls based on the related costs and benefits. It
                  stated that it was DOJ’s belief that the costs of implementing the
                  recommendation, in terms of diversion of attention from substantive
                  issues and generation of extra paperwork, would substantially outweigh
                  any benefits.

                  We recognize that determining whether to implement a particular internal
                  control involves a judgment about whether the benefits outweigh the
                  costs. We believe that the benefits of implementing our recommendation
                  would outweigh any associated costs and paperwork. As stated in this
                  report, these benefits are twofold: requiring documentation would help
                  enable DOJ to (1) determine if its policies and guidance on selecting
                  brokers are being followed and (2) protect DOJ from charges of favoritism
                  towards a specific broker or brokers. Further, noting the reasons for
                  selecting a specific broker in the case file at the time the selection is made
                  would appear to require only minimal paperwork or cost. For example, a
                  concise memo to the file stating the rationale for the selection would
                  suffice.

                  DOJ also expressed concern that, although we observed that most
                  structured settlements have been awarded to a relatively small number of
                  companies, we did not mention that many of the selected companies had
                  multiple offices and brokers that competed for the same work. According
                  to DOJ, by “treating as a monolith all brokers affiliated with the major
                  companies, the draft report ignores the actual way those businesses are
                  run and runs the risk of significantly understating the actual number of
                  brokers competing to handle DOJ structured settlements.”




                  Page 10                         GAO/GGD-00-45 Selection and Use of Annuity Brokers
B-283058




In response, we have noted that according to DOJ, because structured
settlement companies may have multiple offices and brokers, the number
of companies could be misleading. Data were not readily available for us
to determine the extent to which multiple brokers within a single company
competed for the same settlement. Nevertheless, the number and cost of
settlements by brokerage company show that DOJ placed the majority of
its settlement work with a relatively small number of companies—a
situation that still could open it up to charges of favoritism towards these
companies.

Cognizant officials at HHS, VA, Air Force, Army, Navy, and the Postal
Service said they generally agreed with the information presented in the
report. The Army provided additional information to clarify its policy for
selecting structured settlement brokers, and we incorporated this
information in the report where appropriate.

We are sending copies of this report to Senator Orrin G Hatch, Chairman,
and Senator Patrick J. Leahy, Ranking Minority Member, Senate
Committee on the Judiciary; Representative Henry J. Hyde, Chairman, and
Representative John Conyers, Jr., Ranking Minority Member, House
Committee on the Judiciary; and the Honorable Janet Reno, the Attorney
General. We are also sending copies to other interested congressional
parties. Copies will also be made available to others upon request.

If you or your staff have any questions, please call me or Weldon McPhail
on (202) 512- 8777. Key contributors to this assignment were Mary Hall and
Jan Montgomery.

Sincerely yours,




Richard M. Stana
Associate Director, Administration
  of Justice Issues




Page 11                        GAO/GGD-00-45 Selection and Use of Annuity Brokers
Contents



Letter                                                                                                 1


Appendix                                                                                              14

Comments From the
Department of Justice
Tables                  Table 1: Annuity Settlements for DOJ (May1997 to May                           8
                          1999)




                        Abbreviations

                        AUSA          Assistant United States Attorney
                        DOJ           Department of Justice
                        EOUSA         Executive Office for United States Attorneys
                        FTCA          Federal Tort Claims Act
                        HHS           Department of Health and Human Services
                        NSSTA         National Structured Settlement Association
                        VA            Department of Veterans Affairs
                        VICP          National Vaccine Injury Compensation Program




                        Page 12                        GAO/GGD-00-45 Selection and Use of Annuity Brokers
Page 13   GAO/GGD-00-45 Selection and Use of Annuity Brokers
Appendix

Comments From the Department of Justice




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Appendix
           Comments From the Department of Justice




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Appendix
           Comments From the Department of Justice




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